Due diligence on a Belgian company: a first-pass checklist from public sources
Tips
The short answer
Before you sign a partnership, a letter of intent, a large contract or a supplier deal with a Belgian company, you can run a first-pass due diligence from public sources in an afternoon. Check the company's identity and legal status in the KBO, its legal form and statutes, who its directors are and what else they run, who owns it, four years of filed accounts at the National Bank, its publications in the Official Gazette, any insolvency procedure, and its VAT and Peppol status. Accounts are due seven months after year end, so a missing filing is a signal. The UBO register is no longer open to everyone: since 17 February 2023 the public needs to meet one of three conditions. None of this replaces the legal and financial due diligence your advisers do.
The rules and register fields below come from the Code of Companies and Associations on Justel, KBO Public Search, the National Bank, the Official Gazette, FPS Finance and einvoice.belgium.be, read on 1 October 2026. This is general information, not legal or financial advice.
What a first pass is, and what it is not
A first pass answers one question: is there anything in the public record that should stop you, slow you down or change the terms? Legal and financial due diligence is a different job: lawyers and accountants work through a data room (contracts, change-of-control clauses, litigation, tax and social security positions, employment terms, off-balance-sheet commitments, quality of earnings), and the result feeds warranties and the price. A public-source check tells you whether that work is worth starting and which questions to ask first. It cannot see what a company has not filed or published.
The checklist
Check | Source | Free or paid | What it tells you |
|---|---|---|---|
Identity and status | KBO Public Search | Free | Whether it exists, where, since when, and its legal situation |
Legal form and statutes | KBO, notaries' statutes database, Official Gazette annexes | Free | Liability, purpose, who can bind the company |
Directors and their other mandates | KBO Functions, Gazette, annual accounts | Free per company; cross-company views are paid | Who holds a mandate, since when, and recent changes |
Beneficial owners (UBO) | UBO register, FPS Finance | Restricted access | The natural persons who ultimately own or control the entity |
Shareholders and group | Share register at the seat, annual accounts, Gazette | Register not public; accounts free | Direct shareholders, subsidiaries and participations, parent company |
Filed accounts, four years | National Bank, Consult application | Free | Trend in equity, debt, cash, results and staff; filing discipline |
Gazette publications | Official Gazette annexes for legal persons | Free | Capital and share changes, director changes, office moves, mergers, dissolution |
Insolvency | KBO legal situation, Gazette | Free | Bankruptcy, judicial reorganisation, liquidation |
VAT and Peppol | KBO, VIES, Peppol lookup | Free | VAT registration, valid number, e-invoice reachability |
Withholding obligation (some sectors) | checkinhoudingsplicht.be | Free | Whether you must withhold part of an invoice for social or tax debts |
Identity, status and legal form
Start in KBO Public Search with the enterprise number. Read two fields: Status says whether the entity is still registered, and Legal situation (Rechtstoestand) is where bankruptcy, reorganisation or liquidation appear. The same page shows the legal form, the registered office and since when, establishment units, qualities such as "subject to VAT" and "RSZ employer" with start dates, and companies absorbed by this one.
The legal form tells you who is liable. A BV or NV limits shareholder liability; in a general or limited partnership (VOF, CommV) partners are liable without limit, and small partnerships do not have to file accounts at all. Since the 2019 Code a BV has no minimum capital; its founders must give it equity sufficient for the planned activity (art. 5:3). An NV still needs at least 61,500 euros of capital (art. 7:2).
The KBO record links to the notaries' database of statutes and powers of representation. Read the representation clause before anyone signs: it decides whether one director can bind the company alone.
Directors and their other mandates
The Functions section of the KBO lists every current director, manager and person in charge of daily management, with a start date. When a management company holds the mandate, click its number and check that company too. How to find the directors of a Belgian company explains the titles and the permanent representative.
Other mandates are harder: KBO Public Search searches by number, name, activity, authorisation and address, but not by person, so a director's other companies need an aggregated source. Look for companies of the same person that went bankrupt or were struck off. The KBO page also links to the central register of director bans (login required).
Who owns it: UBO, shareholders and group
The UBO register holds the natural persons behind a company. Since 17 February 2023, following an EU Court of Justice judgment, members of the public must meet one of three non-cumulative conditions, while competent authorities and reporting entities such as banks keep access. The Belgian UBO register guide sets out the conditions.
The share register is not public either. A BV or NV keeps it at its registered office, and holders of securities may consult the whole register for their category (art. 5:24 and 7:28). In a deal, ask for a copy. How the Belgian shareholder register works covers what it contains.
The annual accounts fill part of the gap: companies file a list of their participations with the percentage held (art. 3:12), and the full model, unlike the micro model, has a section on the shareholder structure at year end.
Four years of filed accounts
The National Bank's Consult application lets anyone view annual accounts filed since 1999. Accounts must be filed within thirty days of approval and at the latest seven months after year end (art. 3:10). Filing more than a month late costs a surcharge of 400 to 1,200 euros, or 120 to 360 euros for small companies using the shorter models (art. 3:13). Late filing is a signal in itself.
Put four years side by side: equity, debt, cash, operating result and headcount. How to calculate EBITDA from Belgian accounts shows which codes to use.
Official Gazette publications
Appointments, resignations, statute changes, office moves and restructurings are published in the annexes for legal persons. You can filter by subject, including "capital - shares", "resignations - appointments", "restructuring", "end" (cessation, judicial reorganisation) and "ex officio striking off". How to track mergers and demergers in Belgium explains the restructuring trail.
Insolvency, VAT and Peppol
The KBO legal situation gives the yes or no on bankruptcy and judicial reorganisation; the Gazette gives the judgment, the trustee and the creditors' deadline. How to check whether a Belgian company is bankrupt walks through both.
Check that the VAT number validates in VIES. Since 1 January 2026, Belgian VAT-registered businesses must exchange structured electronic invoices, so check that the counterparty can receive them on Peppol. In construction, ready-mix concrete, security and meat, run the withholding check: for a contractor with debts you withhold 35% of the invoice excluding VAT for social security debts and 15% for tax debts.
Red flags
A legal situation other than "normal situation" in the KBO.
Accounts filed late, or not at all, for a company that has to file.
Equity falling for several years, or negative.
Several director changes or office moves in a short period, or a director whose other companies failed.
A group structure nobody can explain, or a refusal to show the share register.
A VAT number that does not validate.
The person signing has no mandate in the KBO or under the statutes.
Doing it for more than one company
In Bizzy, each Belgian legal entity has one record: legal form, VAT and establishments from the KBO, four years of National Bank financials (revenue, gross margin, EBITDA, equity, cash, working capital, FTE), a Directors tab, an Ownership tab with a group tree (parents, percentages, countries, foreign subsidiaries) and a shareholders view, and Official Gazette documents filterable by type. Vista Capital Advisors, a Brussels M&A firm, uses it for buyer lists and market studies. For onboarding checks, see KYC and KYB in Belgium.
Frequently asked questions
What does due diligence mean? Checking a company before you commit to it. A first pass uses public sources; full legal and financial due diligence is done by advisers with access to the company's own documents.
Can I see who owns a Belgian company? Partly. The UBO register is only open to the public under one of three conditions since 17 February 2023, and the share register is kept at the company's seat. The annual accounts show participations and, in the full model, the shareholder structure.
How many years of accounts should I check? At least four, to see a trend in equity, debt, cash and results, and check the filing dates: accounts are due at the latest seven months after year end.
How do I know if a Belgian company is bankrupt? Read the legal situation field in KBO Public Search, not the status field, then the judgment in the Official Gazette.
Photo: the Palace of the Prince-Bishops in Liège, Michielverbeek, CC BY-SA 4.0, via Wikimedia Commons